DIVISION
INSTRUCTION
MIOSHA
Consultation Education & Training Division
Michigan Occupational Safety and Health Administration
Department of Labor and Economic Growth
DOCUMENT IDENTIFIER:
DATE:
CET-ADM-06-03
October 19, 2006
SUBJECT: Hazard Assessment/Personal Protective Equipment Program
ABSTRACT
I.
Purpose:
This instruction establishes the Michigan Occupational Safety and
Health Administration (MIOSHA) Consultation Education and Training
Division (CET) hazard assessment, policies and procedures for staff use
of personal protective equipment (PPE), employer or employee-owned.
II.
Scope:
This instruction applies to all CET staff use of PPE, employer or
employee-owned. This instruction does not cover respiratory
protection, electrical protective equipment, and job tasks involving
exposure to blood or other potentially infectious materials. The
instruction addresses hazard assessments, equipment selection, staff
training, and record keeping requirements contained in MIOSHA
Personal Protective Equipment standards.
III.
References:
A. Agency Instruction MIOSHA-ADM-05-1, MIOSHA Hearing
Conservation Program.
B. Agency Instruction MIOSHA-ADM-06-4, MIOSHA Personal
Protective Equipment Program.
C. Agreement between the State of Michigan and the Michigan State
Employee Association, Article 19, Section E, G & H.
D. Agreement between the State of Michigan and the SEIU local 517M, Section 36, B & D.
E. Michigan Department of Civil Service Regulation 5.14Maintenance Allowances and Reimbursements.
F. MIOSHA Standards, Construction Part 6, General Industry Part 33,
and Occupational Health Part 433, “Personal Protective
Equipment.”
CET-ADM-06-03
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Hazard Assessment/Personal Protective Equipment Program
G. OSHA 29 CFR 1910.132, Personal Protective Equipment.
H. OSHA 29 CFR 1926.28, Personal Protective Equipment.
IV.
Distribution:
MIOSHA, CET staff; Agency S-drive public folder accessible.
V.
Cancellations:
This instruction supersedes any other division documents for CET staff,
policies or procedures regarding personal protective equipment.
VI.
Contact:
Nella Davis-Ray, CET Program Manager
VII.
Originator:
____________________________
Connie O’Neill, Director
Consultation Education and Training Division
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I.
Purpose. This instruction establishes the MIOSHA CET hazard assessment, policies and
procedures for staff use of personal protective equipment (PPE), employer or employeeowned.
II.
Scope. This instruction applies to all CET staff use of PPE, employer or employeeowned. This instruction does not cover respiratory protection, electrical protective
equipment, and job tasks involving exposure to blood or other potentially infectious
materials. The instruction addresses hazard assessments, equipment selection, staff
training, and record keeping requirements contained in MIOSHA Personal Protective
Equipment standards.
III.
References. This procedure incorporates the requirements of:
A.
Agency Instruction MIOSHA-ADM-05-1, MIOSHA Hearing Conservation
Program.
B.
Agency Instruction MIOSHA-ADM-06-4, MIOSHA Personal Protective
Equipment Program.
C.
Agreement between the State of Michigan and the Michigan State Employee
Association, Article 19, Section E, G & H.
D.
Agreement between the State of Michigan and the Michigan Professional
Employees Society, Article 5, Section C.
E.
Michigan Department of Civil Service Regulation 5.14-Maintenance Allowances
and Reimbursements.
F.
MIOSHA Standards, Construction Part 6, General Industry Part 33, and
Occupational Health Part 433, “Personal Protective Equipment.”
G.
OSHA 29 CFR 1910.132, Personal Protective Equipment.
H.
OSHA 29 CFR 1926.28, Personal Protective Equipment.
IV.
Cancellation. This Instruction supersedes any other division documents for CET staff,
policies or procedures regarding personal protective equipment.
V.
Responsibilities.
A.
CET Management.
1. Appoint a CET PPE Program Committee.
2. Review and approve all changes to the CET PPE program.
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Hazard Assessment/Personal Protective Equipment Program
3. Approve the selection and purchase of employer & employee-owned PPE.
4. Ensure the periodic evaluation of the CET PPE program.
5. Certify the completion of the CET hazard assessment (see Appendix A).
B.
CET PPE Program Committee.
1. Conduct workplace hazard assessments to determine the presence of hazards
that necessitate the use of PPE.
2. Periodically evaluate the suitability of previously selected PPE.
3. Review, update, and evaluate the overall effectiveness of the PPE Program.
4. Provide training and technical assistance to CET staff on the proper use, care,
and cleaning of approved PPE.
C.
CET Supervisors.
1. Ensure that appropriate PPE is provided and made available to employees.
2. Ensure employees are trained on the proper use, care, and cleaning of PPE.
3. Ensure the PPE program elements are followed and that employees properly
use and care for PPE.
4. Seek assistance from the CET PPE program committee to evaluate new
hazards.
5. Ensure defective or damaged equipment is immediately replaced.
D.
CET Staff.
1. Follow the requirements of the MIOSHA and CET PPE programs.
2. Use PPE as necessary.
3. Attend required training sessions.
4. Care for, clean, and maintain PPE as necessary.
5. Inform supervision of the need to repair or replace PPE.
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6. Stay alert to surroundings to avoid unnecessary exposure to hazards while
performing job assignments.
7. Inform supervision when a special situation arises that may require additional
or other PPE.
8. Have available for use: eye, head, toe, and hearing protection when
conducting field activities.
9. Follow customer’s personal protective equipment policies as it relates to their
own safety and health.
E.
Management and Technical Services Division.
1. Process purchase orders for PPE, replacement parts, accessories, and cleaning
supplies.
2. As instructed by the division or unit purchasing the PPE, stock inventories of
PPE in various sizes and styles and ensure that spare parts are available.
3. Service, return to the manufacturer, or contract with a trained technician for
the repair or servicing of PPE.
VI.
Hazard Assessment Criteria. The MIOSHA PPE standards require the assessment of
working conditions to determine hazards that are present, or are likely to be present, that
necessitate the use of PPE. The working conditions of CET field and supervisory staff
change on a daily basis. Staff may be exposed to a variety of safety and health hazards in
the performance of their job tasks. The nature of CET fieldwork prevents this hazard
assessment from being site or job task specific.
Fall protection equipment provided to staff shall only be used as a classroom training
tool. With approval of supervision, designated staff may use personal fall arrest
equipment.
This hazard assessment is based on the expectation that CET field and supervisory staff
will observe and be in proximity to hazardous operations as part of their assigned job
tasks, and therefore may be exposed to hazards during the performance of these tasks.
Based on this expectation, the CET PPE program committee will meet periodically to
determine the suitability of the PPE presently available and as necessary, will select new
or additional equipment that ensures a level of protection required to protect CET staff
from the identified hazards.
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VII.
Hazard Assessment and PPE Selection.
A.
Head Hazards. Performing tasks where the head may be struck by objects,
contact electrical sources, or entangle hair.
1.
2.
3.
Hazards considered.
a)
Suspended loads.
b)
Overhead bump hazards.
c)
Energized wires or equipment.
d)
Falling & flying objects.
e)
Machine parts such as chains, belts, rotating devices, suction
devices, and blowers that can draw in and entangle hair.
Hazards identified.
a)
Construction sites.
b)
Trenching or utility projects where tools or other objects may fall
from above and strike staff on head.
c)
Workplaces with traffic routes located under catwalks or conveyor
belts.
d)
Workplaces with hardhat required areas.
e)
Performing CET job tasks in close proximity to machinery with
moving parts that may pose entanglement hazard for staff with
long hair.
Head protection selected based on hazards identified.
NOTE: Only head protection that meets American National Standards
Institute (ANSI) standard Z89.1-1986, Class A will be purchased or
accepted.
4.
Hair protection: When performing CET job tasks, CET staff must use a
hat, cap, or a net that will completely enclose all loose hair when there is a
danger of hair entanglement in moving machinery or equipment.
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B.
Eye and Face Hazards. Observing tasks that may produce significant airborne
dust/flying particles or projectiles (e.g., sawing, cutting, drilling, sanding,
grinding operations). Performing tasks where staff is observing welding or torch
brazing operations that may produce optical radiation. Performing tasks where
staff is observing operations that may produce eye irritants (e.g., acid mist,
fiberglass, smoke) and/or chemical splash.
1.
2.
3.
Hazards considered.
a)
Chemical splashes
b)
Dust
c)
Irritants
d)
Welding operations
e)
Flying particles
Hazards identified.
a)
Performing CET job tasks where staff is observing tasks (sawing,
cutting, drilling, sanding, grinding operations) that may produce
significant airborne dust/flying particles or projectiles.
b)
Performing CET job tasks where staff is observing welding or
torch brazing operations that may produce optical radiation.
c)
Performing CET job tasks where staff is observing operations that
may produce eye irritants (e.g. acid mist, fiberglass, smoke).
Eye/face protection selected.
a)
All eye/face protection will be equipped with side shields and meet
MIOSHA PPE standard requirements, will be purchased or
accepted for use.
b)
Staff wearing contact lenses must also wear appropriate eye/face
protection devices in a hazardous environment.
c)
Staff wearing prescription lenses shall either incorporate the
prescription in the design of the protective eyewear or fit eye
protection over the prescription lenses.
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d)
C.
Chemical splash goggles and/or face shield shall be used where
appropriate.
Noise Hazards. Performing tasks in work area identified by the employer as a
“hearing protection required” area, or areas too loud to have normal conversation
(approximating 85 dBA). Another rule of thumb is that background noise levels
so loud that one has to shout to be heard three feet away is approximately 90
dBA. CET staff has access to sound level meters (and additional meters will be
purchased for greater availability) so that staff can more accurately assess the
noise exposure in their work environments.
1.
2.
Hazards considered.
a)
Machining
b)
Grinding
c)
Sanding
d)
Pneumatic equipment
e)
Generators
f)
Ventilation fans
g)
Motors
h)
Presses
In accordance with MIOSHA-ADM-05-1, MIOSHA Hearing
Conservation Program, hearing protection is selected to be used where
necessary or where it is required by the employer. Several styles of
hearing protection will be made available (foam earplugs, silicone
earplugs, canal caps, and earmuffs). See IX a) 1-7 for stocked selections.
After assessing the environmental noise level, the proper plug or muff
should be selected so that the resulting noise level at the eardrum falls in a
range between 70 and 85 dBA. Using a hearing protector that reduces the
sound level at the eardrum to less than 70 dBA, may result in
overprotection. In those with significant existing hearing loss (50–60 dB
shift), overprotection may reduce warning signals (e.g. lift truck horn) to
levels that cannot be heard so it is important to select the appropriate
protector. See Appendix C for additional guidance on moderate to low
noise environment hearing protection.
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D.
Hand Hazards. Performing tasks where staff may collect wipe or bulk samples
and have limited hand contact with chemicals. Also, where staff may otherwise
handle abrasive materials or when working in cold weather.
1.
E.
Hazards considered.
a)
Chemicals
b)
Sharp edges, splinters, pointed materials, etc.
c)
Temperature extremes.
d)
Sharp tools, machine parts, etc.
e)
Material handling.
2.
Hazards identified include performing CET job tasks where staff may
collect wipe or bulk samples, and have limited hand contact with
chemicals.
3.
Hand protection selected is chemical resistant. See Appendix B of
MIOSHA-ADM-06-4 for additional selection guidance.
Foot Hazards. Performing tasks where staff is subject to walking on sharp objects
or walking areas where tools, heavy equipment, or other objects may roll, fall
onto, or strike the foot.
1.
2.
Hazards considered.
a)
Heavy materials handled by employees.
b)
Sharp edges or points (puncture risk).
c)
Exposed electrical wires.
d)
Slippery conditions.
e)
Wet conditions.
f)
Construction/demolition.
Hazards identified include performing CET job tasks where staff is subject
to walking on sharp objects or walking in areas where tools, heavy
equipment, or other objects may roll, fall onto, or strike the foot.
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3.
Foot protection selected.
a)
Toe protection (steel-toed footwear).
b)
Puncture resistant soles.
NOTE: Only steel-toed shoes that meet ANSI standard Z.41, 1991 are to
be worn on a construction site. Athletic type shoes, sandals, and other
types of open-toe shoes are not permitted when performing CET job tasks.
F.
Body Hazards. Performing tasks in work areas where body and personal clothing
is subject to splashes of corrosive liquids, flammable, molten metal, sparks,
flames or hot surfaces, contact with sharp or rough surfaces, or heavily
soiled/contaminated surfaces. Performing tasks at unheated or outdoor locations
when there is significant exposure to severe weather conditions. Exposure to
conditions that may cause drowning and exposure to traffic on roadway projects.
1.
2.
Hazards considered.
a)
Intense heat
b)
Splashes of hot metal
c)
Cuts
d)
Radiation
e)
Severe cold weather
f)
Struck by
g)
Chemical exposure
Hazards identified.
a)
Performing CET job tasks in work areas where staff’s body and
personal clothing is subject to splashes of corrosive liquids.
b)
Performing CET job tasks in work areas where staff’s body and
personal clothing is subject to contact with sharp or rough surfaces.
c)
Performing CET job tasks in work areas where staff’s body and
personal clothing is subject to heavily soiled/contaminated
surfaces.
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d)
3.
G.
Performing CET job tasks at outdoor operations (ex. sawmills,
logging, construction) when there is significant exposure to severe
cold weather conditions.
Body protection selected.
a)
Disposable where appropriate (e.g., tyvek).
b)
Untreated natural fiber (e.g., cotton lab coat).
c)
Insulated (e.g., coveralls, jacket).
d)
Reflective vests.
Other Hazards.
1.
Laser
2.
Water
3.
Ionizing radiation
4.
Explosion
5.
Electrical
6.
Fall
NOTE: A hazard assessment for special CET assignment will be done on
a case-by-case basis to determine appropriate head, eye, face, foot, hand,
body, or other protective equipment.
VIII.
IX.
Hazard Assessment Certification. See Appendix A of this instruction.
PPE Selection and Use.
A.
CET selected PPE. Based on identified hazards CET staff may be exposed to
when performing job tasks, the CET PPE Program Committee selected the
following appropriate PPE for issuance and use by CET staff.
1)
Class A hard hat.
2)
Non-prescription safety glasses with full side shields.
3)
Chemical goggles.
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4)
Welding goggles with shade 5 lens.
5)
Chemical resistant gloves which include Disposable Polyethylene
Gloves, Pre-Powdered Vinyl Gloves, Vinyl Gloves, Latex Rubber
Gloves, Natural Rubber Gloves, and Nitrile Gloves.
6)
Disposable coveralls.
7)
Earplugs and earmuffs which include Earmuff-Over the Head,
NRR 30 Decibels, Earplugs-Soft Foam, NRR 31 Decibels,
Earplugs-Soft Foam, With Cord, NRR 31 Decibels, Earplugs-PreShaped Foam, With Cord, NRR 33 Decibels, Earplugs-Multi-Sized
Foam, NRR 31 Decibels, Earplugs-Push-Ins, NRR 28 Decibels,
Earplugs-Pod Plugs, NRR 25 Decibels.
B.
State Issued PPE. CET selected PPE may be ordered by staff from the
Management and Technical Services Division (MTSD), Laboratory and
Equipment Services Section (LESS). Equipment Request Form should be used.
Details on the PPE being ordered (size, brand, type) should be entered in the
“Other” section of the form.
C.
Staff owned PPE.
1.
General: Staff-owned and state provided PPE may be selected and used
when performing CET job tasks. Staff-owned protective clothing and
equipment must fit properly, be of safe design and construction for the
work to be performed, be in sanitary and reliable condition, and meet
applicable MIOSHA and ANSI standards.
2.
Foot protection: When performing tasks where foot hazards have been
identified, staff may purchase and use foot protection of their choice.
Selected foot protection must minimally provide toe protection and be
puncture resistant and meet ANSI standard Z.41, 1991 requirements.
3.
Eye protection: When performing CET job tasks where eye hazards have
been identified, staff that wear prescription glasses may use their glasses
as primary eye protection. The glasses should have side shields and need
to meet the requirements of ANSI standard 787.1-1989.
4.
Body protection: Staff performing CET job tasks at outdoor operations
for extended time periods where there is significant exposure to severe
weather conditions may purchase and use body protection of their choice,
in accordance with the CET Cold Weather Protective Clothing Policy
(Appendix B).
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Acceptable examples of cold weather clothing could be, but are not
limited to, brand names such as Carhartts, Dickies and Walls. Athletic
styles, decorative leather, polypropylene shell (or other flammable
material), full length coats, camouflage or hunters orange garments, or
garments not suitable for the work site are not acceptable.
CET staff may be reimbursed for the purchase of body protection in
accordance with applicable Civil Service Commission or collective
bargaining agreement language.
NOTE: CET staff reimbursement for the purchase of foot, prescription
eye, or body protection will be in accordance with applicable Civil Service
Commission or collective bargaining agreement language.
D.
X.
XI.
Client-owned PPE. Client-owned PPE when provided by the client (e.g., safety
glasses or disposable gloves) may be used by CET staff in lieu of CET or staffowned PPE when performing job tasks if the equipment is of safe design and
construction for the work to be performed, in sanitary and reliable condition, and
meets applicable MIOSHA and ANSI standards.
PPE Cleaning and Maintenance.
A.
CET staff will be responsible for inspecting, cleaning, and maintaining PPE at
regular intervals per manufacturer’s recommendations for each item of PPE
provided by CET. The following cleaning equipment is available, and may be
ordered from LESS using the LESS Equipment Request Form. Items include
Personal Safety Equipment Cleaning Pad, 70% Isopropanol, Eyewear Cleaning
Wipes, contain Isopropyl Alcohol, Antiseptic Wipe, 70% Isopropyl Alcohol,
Safety Equipment Cleaner-Sanitizer, Kimwipes EX-L, Non-abrasive Tissue
Paper.
B.
Personal protective equipment worn shall not be shared between employees until
it has been properly cleaned and sanitized. It is also important to ensure that
contaminated PPE that cannot be decontaminated will be disposed of in a manner
that protects employees from exposure to hazards.
C.
All assigned PPE shall be stored in a manner and location that will help prolong
the life of the equipment.
Training. All CET staff assigned PPE shall receive training in the proper use and care of
the equipment. Periodic retraining shall be offered as needed. The training shall include,
but not necessarily be limited to, the following subjects:
A.
When PPE is necessary to be worn.
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XII.
B.
What PPE is necessary.
C.
How to properly don, doff, adjust, and wear PPE.
D.
The limitations of the PPE.
E.
The proper care, maintenance, useful life, and disposal of the PPE.
F.
Inspection of PPE.
Record Keeping. Written records shall be kept of the names of CET staff trained, the
type of training provided, and the dates when training occurred. The CET Division
secretary will enter CET staff training records into the CET training database. The CET
Division secretary shall also maintain the Hazard Assessment Certification form for at
least three years.
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APPENDIX A
HAZARD ASSESSMENT CERTIFICATION
MIOSHA CONSULTATION EDUCATION AND TRAINING DIVISON
(CET)
I certify that a personal protective equipment hazard assessment was performed to the best of my
knowledge and ability, based on the hazards identified for Consultation Education and Training
Division fieldwork. The hazard assessment is contained in CET instruction ______, effective
________.
Certification of training on the use of PPE was conducted on ___________, 20____. Names of
employees trained are recorded in the CET training database. The subjects of training are
discussed in CET instruction _______.
________________________
Signature
______________
Date
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APPENDIX B
CONSULTATION EDUCATION AND TRAINING DIVISION
COLD WEATHER PROTECTIVE CLOTHING POLICY
Background:
Consultation Education and Training Division personnel conduct inspections and investigations
or supervisory visits on construction projects. By its nature, the construction process involves
significant exposure to the elements including cold weather conditions. When Division
personnel are exposed to cold weather, insulated clothing is necessary to protect the body against
its ill effects.
Construction Safety Officers (Michigan State Employees Association Contract Provision):
Secondary language negotiated in Article 22, Section F, Protective Clothing, provides that
Michigan State Employees Association (MSEA) represented employees (safety inspectors) shall
be reimbursed for the purchase of insulated clothing provided they have obtained supervisory
approval.
Insulated Clothing Selection:
Division staff should make responsible choices when selecting apparel. Clothing of good
insulating value, durable strong material, preferably of natural fiber, should be selected. The
apparel must comply with the standards enforced by MIOSHA, required by the site visited, and
conform to other accepted criteria in the construction industry. Insulated coveralls, insulated
bibs or pants & jacket, or insulated coats are allowable. Acceptable examples of cold weather
clothing could be, but are not limited to brand names such as Carhartts, Dickies, and Walls.
Athletic styles, decorative leather, polypropylene shell (or other flammable material), full-length
coats, camouflage or hunters orange materials, or garments not suitable for construction sites will
not be approved.
Use and Care of Insulated Clothing:
Reimbursement is intended only for clothing to be used during hours of employment with
MIOSHA. It is expected the insulated garments will receive adequate care and be serviceable for
one or more winter seasons. Ordinary upkeep (i.e. normal laundering, etc.) of the cold weather
clothing will be the responsibility of the employee. If severe soiling or physical damage occurs
such as grease, oil, paint stains, or rips or tears, the employee should have the garment cleaned
and/or repaired as appropriate. Advance supervisory approval is required for reimbursement
when other than normal repairs or cleaning are necessary (i.e. dry cleaning, tailoring for rips and
tears, etc.).
Reimbursement:
For initial purchase of cold weather clothing, the employee shall notify his/her supervisor of the
intent to purchase and identify the garment to be purchased including brand, constituent
materials, style, cost, and any other information desired by the supervisor to evaluate the
suitability of the apparel. After the supervisor has approved the proposed clothing, the employee
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may make the purchase and submit the receipt for reimbursement. The receipt must be the
original copy and shall indicate the approved type of garment. Regardless of the brand desired,
the most recent Carhartt catalog will be used as a maximum that each supervisor can approve.
(We encourage employees to obtain the most reasonable prices available.) Information on
Carhartt products can be found at www.carhartt.com.
Replacement:
Supervisory approval for replacement of cold weather clothing will be on a case-by-case basis.
Age, wear, soiling, damage, etc. will be considerations in the approval of replacement
reimbursement. The Division safety and health manager must approve replacement items.
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APPENDIX C
CONSULTATION EDUCATION AND TRAINING DIVISION
VARIETY OF PERSONAL HEARING PROTECTION STYLES
August 2006
In some noise environments a standard foam earplug is not protective enough and
earmuffs must be worn in addition to an earplug. In moderate to low noise environments
(85 to 90 dBA), an earplug with a Noise Reduction Rating (NRR) of 33 may be
overprotective if worn properly. Therefore, a variety of hearing protectors will be
supplied to CET staff so that the appropriate noise attenuation can be achieved.
Currently, the following styles of hearing protectors are available upon special requests:
1) EAR Pro Musician (distortion-free earplug)
NRR = 12 dB
2) EAR Ultra 9000 (noise activated earmuff)
NRR = 16 dB
3) EAR Caps
(foam canal caps)
NRR = 17 dB
4) EAR Caboflex
(banded polymer plugs)
NRR = 20 dB
5) Moldex Jazz Band (banded foam insert)
NRR = 25 dB
6) EAR Combat Arms (dual-end polymer plugs)
green end out NRR approx 12 dB
yellow end out NRR = 22 dB
There are additional styles of hearing protection with NRR’s of 30 or greater that the
MTSD/LESS has made available to MIOSHA staff. If there are special needs or fitting
difficulties, additional styles or sizes of hearing protectors can be ordered with your
supervisor’s approval.
There is agreement that NRRs are estimates of the real-world effectiveness of hearing
protection. Some suggest subtracting 7dB from the NRR, some suggest cutting the NRR
in half. Others suggest using both methods in tandem, but that is clearly too conservative
for most low NRR devices.
To achieve an actual attenuation at the eardrum of between 70 and 85 dBA, consider the
following guidance as you select the appropriate protector from the list of NRRated
devices above:
If the noise environment is greater than 100 dBA, use dual protection.
If the noise environment is between 95 and 100 dBA, use a device with an NRR >30.
If the noise environment is between 90 and 95 dBA, use a device with an NRR 20 – 25.
If the noise environment is between 85 and 90 dBA, use a device with an NRR 15 – 20.
If the noise environment is between 80 and 85 dBA, use a device with an NRR 10 – 17.
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APPENDIX D
CONSULTATION EDUCATION AND TRAINING
ICM EQUIPMENT, SUPPLIES AND SERVICE REQUESTS
Please click this link to obtain the equipment form:
http://www.michigan.gov/documents/ICM2006F001v010UC_166963_7.pdf
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